The method (accounting type) seems to be a non-factor, as Walter J. Antonyshyn and Georgiana L. Antonyshyn, 2018 T. C. Memo. 169, filed 10/10/18, reprise Georgina’s real estate professionalism, and do no better than they did in my blogpost “Madness In His Method?” 4/6/16.

Judge Ashford has this one.

Back two years ago, Georgina was fighting a lien after her professionalism claim collapsed.

Now she tries again, but fails. She hired professional management firms to do the day-to-day, so what hours she can substantiate were investor type, and thus fall foul of Reg. Section 1.469-5T(f)(2)(ii)(B).

And her records are internally contradictory and thus unreliable.